An FCRA registration is valid for five years. To keep receiving foreign contribution, the organisation must apply for renewal in Form FC-3C within the six months before the registration expires. Miss that window, or apply with gaps the Ministry can see, and the organisation can lose the right to receive foreign funds at the moment its programmes depend on them.
Renewal is no longer a form-filling exercise. Since the FCRA Amendment Rules 2026, Rule 14A ties renewal to evidence of reasonable activity: at least ₹10 lakh of foreign contribution, received in line with the Act, utilised in the registered field during the previous two financial years. Everything the organisation has filed over five years can now be read together.
Here are ten checks to run at least six months before your expiry date.
This article is for educational and governance purposes only and is not legal advice. Check the current text of the Act, the Rules and the forms on the FCRA portal before you act.
The ten checks
| # | Check | Who owns it |
|---|---|---|
| 1 | Expiry date known, and the six-month window in the Board calendar | CEO, company secretary or FCRA lead |
| 2 | ₹10 lakh of foreign contribution utilised in the registered field over the previous two financial years (Rule 14A) | Finance head |
| 3 | Every FC-4 for the registration period filed on time, and each one agrees with the audited accounts | Finance head, auditor |
| 4 | All foreign contribution received only in the designated FCRA account at SBI, New Delhi Main Branch, and utilisation accounts reconciled | Finance head |
| 5 | Administrative expenses within the 20% limit in every year | Finance head |
| 6 | No foreign contribution transferred to any other person or organisation | Finance head, programme heads |
| 7 | Key functionaries current on the portal, with every change intimated in time | CEO, company secretary |
| 8 | Activities and locations match the registered purposes; FC-6F planned before 21 June 2027 | Programme heads, CEO |
| 9 | Donor records complete, including ultimate donors behind intermediaries | Fundraising, finance |
| 10 | Board resolution, signatory, documents pack and a dry-run review done before the application is submitted | Board, CEO |
Checks 1 and 2: timing and the ₹10 lakh test
1. Know the date. Find the expiry date on the registration certificate or the FCRA portal and put two dates in the Board calendar: the day the six-month window opens, and a target filing date at least two months before expiry. Organisations that discover the date late tend to file in a hurry, with the gaps still in place.
2. Test reasonable activity early. Add up foreign contribution utilised in the registered field in each of the previous two financial years. If the total is close to ₹10 lakh, or utilisation was delayed by a grant gap, the Board needs to know now, not when the application is drafted. Keep the working, linked to the accounts, because it is the first thing a reviewer will test.
Checks 3 to 6: what your past filings already say
3. FC-4 returns. Renewal is read against five years of returns. A missing, late or inconsistent FC-4 is the most common reason an application draws questions. Reconcile each return to the audited accounts, and correct what can still be corrected before you apply. This year’s return is due by 31 December; see the 10 FC-4 checks.
4. Banking. All foreign contribution must arrive in the designated FCRA account at SBI, New Delhi Main Branch. Any receipt into another account, and any mixing of domestic and foreign funds, needs a clear explanation before you apply.
5. The 20% limit. Check administrative expenses against the 20% cap in every year of the period, using the Rule 5 classification. See FCRA administrative expenses: managing within the 20% limit.
6. No onward transfers. Since the 2020 amendment, foreign contribution cannot be transferred to any other person. Look for sub-grants, payments to partner organisations described as “implementation costs”, and shared-cost arrangements that are transfers in substance.
Checks 7 to 9: people, purposes and donors
7. Key functionaries. Make sure the people on record are the people in office, and that each change was intimated on time. Have identity documents for every key functionary ready before the application is opened.
8. Purposes and places. Compare what you actually did, and where, with the purposes in your registration. Under the 2026 Rules, purposes and areas are confirmed through Form FC-6F by 21 June 2027; do not let renewal and FC-6F tell different stories.
9. Donors. Keep a donor register that identifies the ultimate donor behind donor-advised funds and giving platforms. Gaps here now show up in FC-4 and will be visible at renewal.
Check 10: make it a Board decision
Renewal should be approved by the Board, with a named owner, a documents pack and an independent review before submission. The person who prepares the application should not be the only person who checks it. A short paper to the Board covering checks 1 to 9, with any gaps and the fix for each, turns renewal from an admin task into a governance decision.
Questions people ask
When should an NGO apply for FCRA renewal?
Within the six months before the registration expires, in Form FC-3C on the FCRA portal. Plan to file at least two months before expiry so there is time to answer queries.
What is the ₹10 lakh reasonable activity test?
Rule 14A, added by the FCRA Amendment Rules 2026, treats an organisation as having undertaken reasonable activity in its field if it utilised at least ₹10 lakh of foreign contribution, received in line with the Act, during the previous two financial years. It is applied at renewal and in cancellation decisions.
What happens if FCRA registration is not renewed?
The organisation cannot receive foreign contribution once the registration ceases, and the Act governs what happens to unused foreign contribution and assets created from it. The pending FCRA Amendment Bill, 2026 proposes stronger controls over such assets.
Can missing FC-4 returns affect renewal?
Yes. Renewal is assessed against the organisation's filing record. Late, missing or inconsistent FC-4 returns are a common reason for queries.